January 2014 Spray 9 disassembling any part of the container or packaging. Information may be displayed on the bottom of a container as long as it is clearly legible without removing any product packaging. CARB’s standard code that has to be represented separately from other codes on the product container so that it is easily recognizable is the following: YY DDD = Year Year Day Day Day. A manufacturer who uses this standard CARB code to indicate the date of manufacture does not have to report this code. Failure to register a date code is subject to a fine, which seem to go up every year. Your date code explanation needs to be submitted to Enforcement on an annual basis, on or before Jan. 31 of each year. OTC Ozone Transport Commission (OTC) held a meeting on Nov. 14 in Washington, DC, where it voted on a resolution to submit to the U.S. Environmental Protection Agency (EPA). This resolution requests that the EPA adopt the newest Consumer Products Model Rule approved by OTC, as the National Regulation on Consumer Products. This new model rule is significantly more stringent than the current EPA National Rule on Consumer Products. Remember, the EPA National Consumer Products rule was adopted in 1998. Since that time, CARB has had numerous rulemakings and has added many more categories and lowered VOC limits on the existing categories. The OTC model rule does not have all the stringent limits of the CARB rule, but the OTC rule was modeled after an earlier version of the CARB rule. The issue is that there are parts of the U.S., such as the southeast and numerous states out west, that only have the EPA National Consumer Products Regulation to deal with. By updating the rule to the OTC Model Consumer Products rule, some regional manufacturers or national manufactures that have regional products will be subject to significantly lower VOC limits. The question is whether these states and our consumers need these stringent VOC limits. At the meeting, the EPA presented an update of its activities and this issue was not on its list. We will need to wait and see if EPA has the manpower to work on updating their regulation. If they decide to work on this rule, we as the Industry, need to ensure enough time is given to comply with the new limits. Spray We, as an industry, need to ensure enough time is given to comply with the new limits.
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